Silver Star Brands’ Environmental Policy & Vision Statement

Silver Star Brands recognizes how vital it is to incorporate environmental
stewardship in the conduct of business, including the efficient and sustainable
use of natural and economic resources, which incorporates practices such as
energy conservation and preservation of biodiversity. Silver Star Brands is committed
to understanding the impact our organization has on the environment and to continually
improving our environmental performance, while encouraging our suppliers and
customers to do the same.

To this end, we seek to adhere to principles addressing the following eight
areas, and to support these principles through specific initiatives. Our goal
as an organization is to address these key aspects of our environmental
performance as members of the direct marketing community:

PRINCIPLE AREAS

List Hygiene and Data Management

Design

Paper Procurement and Usage

Printing and Packaging

Recycling and Pollution Reduction in our Workplace and
Community

Internal and Supplier Code of Conduct

Green Building

Social & Community Outreach

INITIATIVES IN SUPPORT OF PRINCIPLE AREAS

I. LIST HYGIENE AND DATA MANAGEMENT

Silver Star Brands continually endeavors to manage data and lists in an
environmentally responsible manner with a focus on reducing the amount of
duplicate, unwanted and undeliverable mail [to both consumers and businesses].
To achieve our goals in this area:

A. We Maintain Suppression Lists

We maintain in-house do-not-market lists for prospects and
customers who do not wish to receive future solicitations from us
(required by DMA Privacy Promise).

B. We Offer Notice & Choice

We provide periodic notices and opportunities for
customers to opt in or opt out of receiving future marketing contacts from
our organization (required by DMA Privacy Promise).

We provide periodic notices and opportunities for
prospects to opt in or opt out of receiving future marketing contacts from
our organization.

We offer customers a choice to receive communications from
our organization electronically.

C. We Clean Our Lists Prior to Mailing

In addition to use of the Direct Marketing Association
(U.S.) Mail Preference Service (MPS) on all applicable consumer
prospecting lists, we maintain clean, deliverable files by using:

ZIP Code correction

Address standardization

USPS National Change of Address (NCOA)

Other USPS products such as

Address Element Correction (AEC),

Delivery Sequence File (DSF),

Address Correction Requested (ACR)

Predictive models and RFM segmentation

We use the DMA "Deceased Do Not Contact" list to
eliminate names of deceased persons from mailings.

D. We Merge/Purge Our Data

We match outside lists against each other to prevent
duplicates.

We use match definitions in merge/purge that minimize
duplicates.

We match outside lists against other commercially
available suppression files where appropriate.

E. We Test Market Offers

We test a sample of a list before mailing or marketing to
the entire list.

We test different versions of advertising and marketing
offers, in mail and other media, to select those offers and media
combinations that receive the best response.

II. DESIGN, PRODUCTION AND PRINTING IN OUR MAIL, MARKETING AND
COMMUNICATION MATERIALS

Wherever feasible, in designing and printing communications, we look at
opportunities for source reduction. We also communicate this goal to our
suppliers. To this end:

A. We Reduce the Amount of Waste

We review periodically direct mail and direct marketing
packages and downsize when and where appropriate.

We test and use lighter-weight papers wherever feasible.

We adjust trim sizes of our publications and/or collateral
in an effort to reduce waste.

We test and use production methods that reduce print order
overruns, waste allowances and in-process waste.

C. We Give Preference to Recyclable and/or Reusable Materials

We routinely survey the marketplace for high recycled
content for corrugated boxes and packing materials and/or recyclable or
reusable materials.

We seek to utilize recycled printing and writing paper
with post-consumer content when and where feasible; and where measured
environmental improvements occur.

We ensure, where possible, that all packing and packaging
materials are made of recyclable (collected locally throughout the
country), recycled, reused or reusable materials.

D. We Communicate Environmental Principles to Suppliers

We require supplier companies to comply with all
applicable laws and regulations in respect of protecting the environment

III. PAPER PROCUREMENT AND CLEAN PRODUCTION

Silver Star Brands recognizes that improving forestry practices is an important
component of environmental stewardship and sustainability. We strive to
procure, use, and recover paper in a manner that helps to ensure the
sustainable use of forests and other natural resources. In support of this
principle:

A. We Research & Understand Our Investment in Paper

§We work to understand the investment our company has in paper.

§We invest time and resources to understand and address
environmental issues associated with paper procurement.

§We strive to identify our "fiber supply chain" for
forest products we use, such as paper for catalogs and other marketing
materials, and corrugated packaging.

We require that our paper suppliers have made a commitment
to implementing sustainable forestry practices that protect forest
ecosystems and biodiversity as well as provide the wood and paper products
our company needs.

Wherever feasible we specify that paper suppliers use
third-party, verified traceability or chain-of-custody so that we know the
origin of fiber in our paper.

We avoid paper from sources that are known to log
unsustainably or illegally managed forests.

We recognize the importance of maintaining biodiversity
and will work with suppliers who have integrated conservation values and
programs into their operations.

We give preference to paper suppliers which are certified
and verified by an independent third party.

Currently our suppliers adhere to standards maintained
by:

CSA (Canadian Standards Association)

FSC (Forest Stewardship Council)

PEFC (Program for the Endorsement of Forest
Certification)

SFI (Sustainable Forestry Initiative)

We give preference to suppliers who conform to
International Organization for Standardization (ISO) 14001 environmental
management standards for manufacturing and forestry practices.

We give preference to suppliers which use loggers who have
been properly trained in recommended harvesting and reforestation methods.

We aim for continuous improvement in the percentage of
certified wood fiber in our paper (in other words, fiber from third-party
certified forests).

D. We Encourage Responsible Use of Forest Resources

We evaluate paper used for marketing pieces and internal
consumption to identify opportunities for increased post-consumer recycled
content, lower basis weights and other environmental attributes.

Whenever the economics are sound and the environmental
benefits clear, we purchase paper with recycled content, including papers
with post-consumer content

We negotiate with our paper suppliers about purchasing
papers with post-consumer recycled content at a comparable price,
environmental impact and performance to virgin papers

We print order forms, blow-ins and order envelopes on
paper with a higher percentage of post-consumer recycled content whenever
feasible.

We reduce the amount of raw materials used to make our
products by encouraging the development of lighter-weight grades of paper
that meet our organization’s functional and quality needs.

From 2005 to 2007 our use of lighter weight paper has
reduced our total wood use by 1,472 tons, or 10,191 trees. The energy
saved was 21,806 million BTU’s, enough to power 240 homes each year.
Greenhouse gases were reduced the equivalent of 4,364,582 lbs CO2, or the
emissions from 396 cars per year. Wastewater was reduced 10,219,474
gallons. Click here for more details.

Silver Star Brands believes that sourcing environmentally preferred papers and
other materials is only a beginning. Equally important is efficient use of
papers and materials once they are purchased.

·Our shipping containers contain over 60% post-consumer content.

·We work continually to eliminate unnecessary packaging materials
that do not protect merchandise or enhance its presentation before prospects
and customers.

We continually monitor the use of our packaging material
to minimize usage yet provide adequate protection for our merchandise. In
our fulfillment, we implement packaging guidelines that optimize the ratio
between the size of outgoing shipments and the size of cartons used.

In our fulfillment, we use reusable packaging that allows
customers to return items in the same package used for shipping to ease
the return process.

We sort incoming packaging materials for recycling
collection.

We reuse incoming packaging materials for outgoing
shipments where possible.

Silver Star Brands’ policies and initiatives in this area are guided by the Three
R’s: "Reduce, Reuse, and Recycle." With this in mind, we seek an
efficient and environmentally sensible workplace, as well as to promote
environmental stewardship in our community. Toward this principle,

A. We Reduce & Reuse in the Workplace

Where possible and practical, we buy office papers,
packing and packaging materials made from recycled materials with
post-consumer content.

Where practical we will use recyclable materials and
materials that don’t hinder the recycling process.

We integrate the use of electronic communications (e-mail,
Web and intranet) for external and internal communications.

We make primary use of two-sided printing and photocopying
where appropriate.

We develop online systems for reports, projects and
monitoring to reduce paper generation.

We reuse office supplies such as file folders, hanging
folders and binders where appropriate.

We substitute durable materials for disposable products
where possible.

B. We Deploy Recycling in Our Workplace

We implement in-house recycling programs for:

Paper

Corrugated cardboard

Beverage cans and bottles

Plastics

Pallets

Toner cartridges

Personal and laptop computers. 3 year lease ensures most
current energy conservation technology.

We annually recycle 600 tons of cardboard, 60 tons of
office paper, and 6 tons of other materials

We participate in existing industry-specific or government
programs for:

Energy savings

We have made recent lighting improvements at our
distribution center that saves over 1,100,000 kwh of electricity
annually. Click here for more detail.

VI. INTERNAL AND SUPPLIER CODE OF CONDUCT

Silver Star Brands is committed to enforcing an internal code of conduct that
provides for a safe and fair working environment for its team members. We also
recognize that it is this code of conduct that must be the basis for evaluating
current and potential suppliers. Silver Star Brands maintains the following codes and
policies:

A. Equal Employment Opportunity

·We support and have a strong commitment to equal opportunity.

·We recruit, train, hire, transfer, promote, compensate, and make
all employment related decisions without regard to an individual’s race, color,
religion, age, sex, national origin or ancestry, marital status, physical or
mental disability, sexual orientation, or any other protected status as
required by law.

B. Safety and Health

·We strive to make our workplace as safe and healthy as possible
by meeting or exceeding all local, state, and federal (OSHA) workplace safety
requirements.

·We have established a workplace safety program monitored by our Facilities and Safety Leader and our Safety
Committee.

·We are committed to providing a work environment that is free
from all forms of discrimination and conduct that could be considered
harassing, coercive, or disruptive, including sexual or any other illegal
harassment.

D. Supplier Code of Conduct

·We seek to partner with suppliers that are committed to ethical
conduct, meet the above requirements regarding equal opportunity, safety and
health, and harassment as well as the following:

Child Labor - Suppliers shall not use child labor.
“Child” is defined as a person who is not older than the local age for
completing compulsory education but in no event is less than 15 years of
age. Suppliers must verify the age of their workers and maintain copies
of their workers’ proof of age. Suppliers must follow all applicable
laws and regulations regarding working hours and conditions for minors

Involuntary Labor - Supplier shall not use involuntary
labor. “Involuntary Labor” is defined as work or service which is
extracted from any person under threat or penalty for its non-performance
and for which the worker does not offer himself or herself voluntarily,
and includes all manner of prison, bonded, indentured and forced labor.

Disciplinary Practices - Suppliers shall not use corporal
punishment or any other form of physical or psychological coercion or
intimidation against workers.

Non-discrimination - Suppliers shall employ workers
solely on the basis of their ability to do the job, and shall not
discriminate on the basis of age, gender, racial characteristics,
maternity or marital status, nationality or cultural, religious or
personal beliefs or otherwise in relation to hiring, wages, benefits,
termination or retirement.

Health and Safety - Suppliers shall maintain a clean,
safe and healthy workplace in compliance with all applicable laws and
regulations. Suppliers shall ensure that workers have access to clean drinking
water, sanitary washing facilities and an adequate number of toilets,
fire-extinguishers, and fire exits and that workplaces provide adequate
lighting and ventilation. Suppliers shall ensure that the aforementioned
standards are also met in any canteen and/or dormitory which is provided
for workers.

Environmental Protection - Suppliers shall comply with
all applicable laws and regulations in respect of protecting the
environment and maintain procedures for notifying local authorities in
the event of an environmental accident resulting from Suppliers’
operations.

Wages and Benefits - Suppliers shall provide wages and
benefits that comply with all applicable laws and regulations or match
the prevailing local manufacturing or industry rates, whichever is
higher. Overtime pay shall be calculated at the legally required rate,
regardless of whether workers are compensated hourly or by piece rate.

Working Hours - Suppliers shall not require workers to
work, including overtime, more than 60 hours per week or more than any
maximum number of hours per week established by applicable laws and
regulations, whichever is less. Suppliers shall guarantee that workers
receive at least one day off during each seven-day period.

Freedom of Association - Suppliers shall respect the
right of workers to associate, organize and bargain collectively in a
legal and peaceful manner.

Familiarization and Display of This Code of Conduct - Suppliers
shall familiarize workers with this Code of Conduct and display this Code
of Conduct, translated in the local language, at each of their facilities
in a place readily visible and accessible to workers.

Legal Requirements - Suppliers shall comply with all
legal requirements applicable to the conduct of their businesses,
including those set out above.

Contractors and Suppliers - Suppliers shall ensure that
their contractors and suppliers adhere to this Code of Conduct.

Monitoring of Compliance - Suppliers authorize Silver Star Brands and its principals to conduct scheduled and unscheduled inspections
of Suppliers’ facilities for the purpose of ensuring compliance with this
Code of Conduct. During these inspections, Silver Star Brands and its
principals shall have the right to review all employee-related books and
records maintained by Suppliers and to interview workers.

Corrective Action - When violations are found, Silver Star Brands and the Supplier concerned will agree on a corrective action plan
that eliminates the problem in a timely manner. If it is determined that
a Supplier is knowingly and/or repeatedly in violation of this Code of
Conduct, Silver Star Brands and its principals shall take appropriate
corrective action, which may include cancellation of orders and/or
termination of business with the Supplier in question.

VII. GREEN BUILDING

Silver Star Brands participates in Wisconsin Focus on Energy program for
training and assistance in energy conservation projects. These Green Building initiatives include best practices in Lighting, HVAC and Air Compressors operations
to reduce operating costs and conserve energy. Silver Star Brands will consider LEED
(leadership in energy and environmental design) guidelines in maintaining the
building and future building projects.

·We made recent lighting improvements at our distribution center
that will save over 1,100,000 KWH of electricity annually. This is the
equivalent of 2,640,000 lbs. of CO2 not introduced into the environment, or
2,162 barrels of oil not burned.

·We strive to substitute current products and services for
environmentally preferred products and services whenever they perform
satisfactorily and are available at reasonable prices.

·Our contracted janitorial service uses environmentally friendly Green
Cleaning supplies, equipment, and methods to improve indoor air quality that
translates into a healthy working environment for employees and visitors.

Silver Star Brands is a socially responsive company with a strong history of
giving in the community. We encourage our team members to give of their time
and money whenever possible. Recent efforts by the team members include:

·Silver Star Brands' team members donate to the United Way with
automatic payroll deductions.

·Participation in and donations to the local Walk to Cure
Diabetes sponsored by Juvenile Diabetes Research Foundation

·Participation in and donations to the local annual Heart Walk sponsored
by the American Heart Association

·Hosted 4 company blood drives during the last 12 months

·Donations to American Red Cross hurricane Katrina disaster
fund

Silver Star Brands is committed to continually improve our environmental
performance. We endeavor to make responsible, sound business decisions and
wherever feasible integrate environmental considerations into all aspects of
our operations. We readily acknowledge that environmental stewardship is an
ongoing challenge and a continual learning experience. We continue to research
best practices and to explore the possibility of partnerships with other
companies, environmental and conservation organizations, and local communities,
all with the intent of further strengthening our environmental stewardship.